Version:	Review date:	Edited by:	Approved by:	Comments:
V1	16/1/2025	Salma Ali	Practice Manager

Table of contents

1     Introduction

1.1      Policy statement

1.2      Status

2     The Freedom of Information Act 2000 (FOIA)

2.1      Principles

2.2      Roles and responsibilities

2.3      Defining a valid request for information

2.4      Duty to provide advice and assistance

2.5      Time limits for compliance with requests

2.6      Exemptions and Public Interest Test

2.7      Charges and fees

2.8      Acknowledgement and logging of requests

2.9      Vexatious or repeated requests

2.10     Refusal of a request

2.11     Means by which information will be conveyed

2.12     Disclosure log

3     Appeals process

3.1      Internal review

3.2      External review

4     Transferring requests for information

4.1      Process

5     Public sector contracts

5.1      Overview

6     Third parties

6.1      Consultation from third parties

7     Model publication scheme

7.1      Information publication

8     Training

8.1      eLearning

Annex A – FOI request template

Annex B – Exemption information under Part II

Annex C – Timeline of process, considerations and actions

Annex D – FOI request checklist

Annex E – FOI acknowledgement letter template

Annex F – FOI response letter template

Annex G – PIT requirement delay letter template

Annex H – Record of PIT meeting template

Annex I – Freedom of Information request register

Annex J – Disclosure log template

Annex K – Organisation publication scheme

1 Introduction

1.1 Policy statement

The purpose of this document is to ensure that staff and patients at Greengate Medical centreare aware of the ways in which the organisation adheres to the Freedom of Information Act 2000 (referred to as the Act herein). The Act enables the public to access information held by public authorities in two ways:

• Public authorities are obliged to publish certain information about their activities
• Members of the public are entitled to request information from public authorities who, in turn, are required to provide the requested information within 28 working days, unless it is exempted

The policy will provide a framework within which this organisation will ensure compliance with the requirements of the Act and will underpin any operational procedures and activities connected with the implementation of the Act.

It is important to note that the Act does not give individuals access to their own personal data, i.e., healthcare records. This is processed by means of a subject access request.

To help staff to understand this subject, a range of Information Commissioners Office (ICO) videos are available on YouTube.

1.2 Status

The organisation will aim to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the organisation and other individuals performing functions in relation to the organisation such as agency workers, locums and contractors.

2 The Freedom of Information Act 2000 (FOIA)

2.1 Principles

The ICO advises that the main principle behind the Act is that people have a right to know about the activities of public authorities, unless there is a good reason for them not to.  This means:

• Everybody has a right to access official information
• Applicants do not need to give a reason for wanting the information. On the contrary, organisations must justify refusing to provide the information
• All requests for information must be treated equally except under some circumstances relating to vexatious requests and personal data. Furthermore, all requesters are to be treated equally, whether they are journalists, local residents, public authority employees or foreign researchers
• As all requesters are treated equally, information under the Act should only be disclosed if it would be disclosed to anyone else who asked

Information can be shared voluntarily outside the provisions of the Act.

2.2 Roles and responsibilities

• Caldicott Guardian

The Caldicott Guardian has ultimate responsibility for the organisation’s compliance with the Act and is responsible for providing advice and support to all staff.

• Organisation Manager

The Organisation Manager, in their role as Senior Information Risk Owner (SIRO), is responsible for providing advice and guidance to all staff and they are also the nominated person to carry out an internal review of a response to a freedom of information (FOI) enquiry.

• Data Protection Officer

The Data Protection Officer will provide expert advice with regard to the information request, the response and appeal process, if appropriate.

• All staff

All staff, including contractors, are responsible for ensuring that any requests for information that cannot be considered to be ‘business as usual’ and therefore fall under the Act are forwarded to the Organisation Manager immediately.

Furthermore, all staff, including contractors, are responsible for responding to requests for information received from the Organisation Manager in order to comply with the Act in a timely manner.

2.3 Defining a valid request for information

Any individual has the right to request information from a public authority and this organisation has two separate duties when responding to such requests:

• Inform the applicant whether the organisation holds any information falling within the scope of their request
• To provide that information, Section 8 of the Act states that for the request to be valid, it must:

• Be in writing (but requesters do not have to mention the Act or direct their request to a designated member of staff)
• Detail the name and address of the applicant (email address is valid)
• Describe the information requested
• Be legible
• Be capable of being used for a subsequent reference

A request also becomes valid when the Act is detailed in correspondence.

A FOI request form template is provided in Annex A.

2.4 Duty to provide advice and assistance

Under Section 16 of the Act, this organisation has a duty to provide advice and assistance to individuals making requests. This organisation will strive to take all reasonable steps to meet this duty.

2.5 Time limits for compliance with requests

As detailed in Section 10 of the Act, the organisation has a duty to respond to requests within 28 Working Days of receipt of the request. Annex D details the process to be followed on receipt of an FOI request. 

Once a FOI request has been received and processed by the Organisation Manager, the request will be forwarded to the Caldicott Guardian, SIRO and the designated Information Governance (IG) lead who will be given a time scale to respond within 10 working days.

Should a request be unclear, the Organisation Manager will contact the applicant to request clarification. The 28 Working Days‘clock’ does not start until a valid request is received and clarification (if necessary) has been received.

If clarification is requested but not received within 28 Working Days, the request will be considered to have been withdrawn. Should the applicant re-submit their request after this point, it will be treated as a new FOI request.

2.6 Exemptions and Public Interest Test

This organisation will not release information held to which any absolute or qualified exemptions detailed in Part II of the Act apply. There are 25 exemptions detailed at Annex B.

The ICO advises that that the Public Interest Test (PIT) applies if an exemption is qualified and the organisation must weigh the public interest in maintaining the exemption against the public interest in disclosure.

As a result, the PIT may delay the response to the request for information. A template is available at Annex G which informs applicants of the reason for the potential delay.

2.7 Charges and fees

In general, this organisation will not charge a fee for processing a FOI request. However, should there be a request for large volumes of hard copy materials, a fee may be levied. This will be in line with Section 3 of The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004.

2.8 Acknowledgement and logging of requests

All valid requests for information under the Act should be acknowledged within two working days. Annex E provides an appropriate FOI acknowledgement letter template meeting these requirements. Annex I provides an appropriate FOI request log template while Annex H provides an appropriate PIT meeting template.

2.9 Vexatious or repeated requests

This organisation is not obliged to comply with a request for information if the request is vexatious. When this organisation has previously complied with a request for information that was made by any person, it is not obliged to comply with a subsequent identical or subsequent similar request from that person unless a reasonable interval has elapsed between compliance with the previous request and the making of the current request.

This organisation will log all requests for information for monitoring purposes and will be able to identify repeated or vexatious requests. 

2.10 Refusal of a request

Should this organisation refuse a request, the applicant will be advised of the reasons why within 28 Working Days. They will also be provided with information on how to make a complaint about the refusal.

When it is not possible to confirm that an exemption applies, this organisation will inform the applicant that the issue remains under consideration and will estimate the date at which a firm judgement will be made.  This will be notified to the applicant by issue of an exemption pending notice (see Annex G).

The Organisation Manager will keep a record of all notices issued to refuse requests for information and any information regarding the PIT process.

2.11 Means by which information will be conveyed

This organisation will provide information to applicants in the format requested wherever possible.

2.12 Disclosure log

The disclosure log (see Annex J) provides information that has been released via requests made to this organisation for information under the Act. The disclosure log forms part of the publication scheme and can link to documents available on the scheme which in turn is published on the organisation’s website.

The Organisation Manager must ensure that information from multiple requests regarding the same subject is available via the disclosure log.  If there has been a request made for information which is currently part of a public debate, for example the subject is within the media, this information must be published within the disclosure log.

The requests within the disclosure log must remain anonymous and therefore the requester’s details must not be made available. The only information provided on the disclosure log are the questions asked and the answers to these questions. The reference numbers will also be provided to provide a reference if a member of the public contacts this organisation regarding the information contained within the disclosure log.

3 Appeals process

3.1 Internal review

Should an applicant be dissatisfied with a response that the organisation has provided, they are able to request an internal review. Any complaint about or challenge to the information given in a response to an FOI request should be treated as a request for an internal review.

Any request for an internal appeal should be made within 40 working days of an FOI response being sent. Any requests for an internal review made after this date are out of time and will not receive an internal review. All requests for an internal review will be responded to within 28 Working Days.

To ensure that all reviews are carried out independently, support in compiling the review responses will be provided by the organisation’s Data Protection Officer.

3.2 External review

Should an enquirer be dissatisfied with a response that they have received, under Section 50 of the Act they are entitled to request an external review by the ICO.

Should an appeal be accepted by the ICO, the organisation is obliged to supply the complete audit trail of its response to the Information Commissioner including un-redacted copies of information that has been redacted.

4 Transferring requests for information

4.1 Process

This organisation is permitted to transfer a FOI request when it does not hold the requested information. This organisation recognises that ‘holding’ information includes holding a copy of a record produced or supplied by another person or body (but does not extend to holding a record on behalf of another person).

If the organisation does not hold the requested information, the applicant will be advised accordingly. If, however, the organisation believes that the requested information is held by another organisation, it may:

• Contact the organisation and transfer the request on behalf of the applicant
• ·Contact the application, advising where the information is held and who to contact to request the information

Prior to transferring the request, this organisation will consult with the other organisation involved to determine if it holds the requested information and a transfer is appropriate.

Transfers of requests will take place as soon as is practicable.

5 Public sector contracts

5.1 Overview

When entering into contracts, this organisation must refuse to include contractual terms that attempt to restrict the disclosure of information held by the organisation and relating to the contract beyond the restrictions permitted by the Act. With the inclusion of existing contracts, unless an exemption provided for under the Act is applicable in relation to any information, the organisation may be obliged to disclose that information in response to a request, regardless of the terms of any contract. As recommended by the Lord Chancellor’s Department, this organisation will reject non-disclosure clauses.

6 Third parties

6.1 Consultation from third parties

This organisation recognises that in some cases the disclosure of information may affect the legal rights of a third party, for example when information is subject to the common law duty of confidentiality. Unless an exemption provided for in the Act applies in relation to any information, this organisation will be obliged to disclose that information in response to a request.

When a disclosure of information cannot be made without the consent of a third party and would constitute an actionable breach of confidence such that an exemption would apply, this organisation must consult the third party with a view to seeking its consent to the disclosure, unless such a consultation is not practicable.

The organisation will undertake consultation where:

• The views of the third party may assist the authority to determine whether an exemption under the Act applies to the information requested; or
• The views of the third party may assist this organisation to determine where the public interest lies.

This organisation may consider that consultation is not appropriate when the cost of consulting with third parties would be disproportionate. In such cases, the organisation will consider what is the most reasonable course of action for it to take in light of the requirements of the Act and the individual circumstances of the request. Consultation will be unnecessary where:

• The organisation does not intend to disclose the information relying on some other legitimate ground under the terms of the Act
• The views of the third party can have no effect on the decision of the authority, for example, when there is other legislation preventing or requiring the disclosure of this information
• No exemption applies and therefore, under the Act's provisions, the information must be provided

When the interests of a number of third parties may be affected by a disclosure, and those parties have a representative organisation that can express views on behalf of those parties, the organisation will, if it considers consultation appropriate, consider that it would be sufficient to consult that representative organisation. If there is no representative organisation, this organisation may consider that it would be sufficient to consult a representative sample of the third parties in question.

The fact that the third party has not responded to a consultation does not relieve this organisation of its duty to disclose information under the Act, or its duty to reply within the time specified in the Act. In all cases, it is for this organisation, not the third party (or a representative of the third party) to determine whether information should be disclosed under the Act. If a request for the disclosure of information to which the third party has previously objected is received, under the Act the organisation must review the decision to accept the objection and must provide the information unless it is satisfied that the objection was in fact a valid one.

7 Model publication scheme

7.1 Information publication

The ICO expects this organisation to adopt its model publication scheme and commit to proactively publishing information, explaining what information will be published, the format it will be published in and whether a charge will be made for the information.

8 Training

8.1 eLearning

Information Governance and Data Security eLearning is available in the HUB.

 

Annex A – FOI request template

FREEDOM OF INFORMATION REQUEST

In accordance with the Freedom of Information Act 2000

Completion and submission of this form means that we will be processing your personal information. To find out how we use your personal information please refer to the organisation’s privacy notice for information governance.

The information you supply will be used for the purpose for which you have provided it and any relevant procedures following from this. This data will be maintained in accordance with the Data Protection Act 2018 and will not be passed on or sold to any other organisation without your prior approval unless this is a legal requirement.

Fields marked with an asterisk (*) are mandatory.

*Your Details

*Access to information requested

Please select the preferred form of access to the requested information:

Via email
Receive copies by post
View originals (if practical)

*Apply for access to information under the Freedom of Information Act

Subject of your enquiry:
Describe your enquiry: Provide as much detail as possible; this will help us to process your request quickly and efficiently. Where appropriate, include names, dates, references and descriptions to enable us to identify and locate the required information.

There are two types of class exemption:

• Absolute exemption which does not require a test of prejudice or the balance of public interest to be in favour of non-disclosure.
• Non-absolute exemption qualified by the public interest test which requires this organisation to decide whether it is in the balance of public interest to not disclose information.

With the exception of Section 21 (information available by other means), exemptions apply not only to the communication of information but also to the duty to confirm or deny, if that itself would disclose information that it is reasonable to withhold.

The absolute exemptions under the Act are:

Section	Absolute exemption
Section 21	Information accessible to applicant by other means
Section 23	Information supplied by, or relating to, bodies dealing with security matters
Section 32	Court records
Section 34	Parliamentary privilege
Section 36	Prejudice to effective conduct of public affairs (so far as relating to information held by the House of Commons or the House of Lords)
Section 40	Personal information (where the applicant is the data subject)
Section 41	Information provided in confidence
Section 44	Prohibitions on disclosure

The exemptions that are non-absolute exemptions qualified by the public interest test are:

Section	Qualified exemption
Section 22	National security
Section 24	Information intended for future publication
Section 26	Defence
Section 27	International relations
Section 28	Relations within the United Kingdom
Section 29	The economy
Section 30	Investigations and proceedings conducted by public authorities
Section 31	Law enforcement
Section 33	Audit functions
Section 35	Formulation of Government policy
Section 36	Prejudice to effective conduct of public affairs (for all public authorities except the House of Commons and the House of Lords)
Section 37	Communications with His Majesty, etc. and honours
Section 38	Health and safety
Section 39	Environmental information
Section 40	Personal information (where the applicant is not the data subject)
Section 42	Legal professional privilege
Section 43	Commercial interests

Further information on the exemptions can be found here.

Case reference		Date of receipt
Name of applicant		Target date
Information requested:
Checklist
Establishing if the request is valid The first step in dealing with an FOI request is to establish whether or not the request fulfils the FOI request criteria: Requests for information do not need to mention the Act Anyone can make a request. There are no restrictions for example on the nationality or location of the applicant However, the request must be in writing (email or letter) and include the applicant’s name (pseudonyms can be refused) and postal address or an email address to which a response can be sent The request should describe the information required Consider whether the request should be dealt with under the Data Protection Act 2018 or Environmental Information Regulations 2004
Cost Limit (Section 12 of the Act) Will the cost of locating, retrieving and extracting the information exceed the appropriate limit? The appropriate limit is £450.00 which represents the cost of one person determining whether the information is held within the organisation, locating, retrieving and extracting the information. The limit covers the time taken to find, sort, edit or redact material. You cannot include the time taken to consider whether an exemption applies or the PIT.
Establishing if the information is held A person may request any recorded information held by a public authority (or held by another on behalf of a public authority). Recorded information can be held in the form of documents, emails, notes, videos and audio tapes. If the applicant requires you to create information that is not already held at the time of receipt of the request, you are not obliged to create the information.
Is the information already available on the disclosure log? If the information is already available, then the applicant should be directed to this information in the public domain.
Is the information closely connected with the functions of another public authority? If the organisation does not hold the information that has been requested but you believe another public authority holds it, you should consider the best way to help the requester. In most cases, this will mean contacting the requester and supplying the contact details of the public authority in question, having confirmed beforehand that they do hold the information.
Duty to provide advice and assistance If the request is widely framed, you should consider whether: It would be helpful to consult with the requester to try to narrow or refine the request but only if the cost limit is exceeded How long it will it take to retrieve and extract the information requested
Is it a vexatious or repeated request? There is no need to comply with a request: If it is vexatious, that is: It would impose a significant burden on the organisation It clearly does not have any serious purpose or value It is designed to cause disruption or annoyance It has the effect of harassing the organisation It can otherwise fairly be characterised as obsessive or manifestly unreasonable It is a repeated request, that is: Identical or substantially similar to a previous request from that person or persons you believe to be working together (unless a reasonable amount of time (roughly three months) has elapsed between them)
If we disclose this information, do we need to consult the communications team?
If we do hold this information, should it be released? This depends on whether: Any of the information is personal information, in which case the information is exempt under Section 40 of the Act and fails to be considered under the Data Protection Act. Requests for environmental information should be considered in accordance with Environmental Information Regulations 2004 (EIRs) The information is now or soon to be publicly available in which case you have the discretion to refuse the request (Section 21 or 22 of the Act) but should either provide a link to the information or provide the applicant with details of where the information can be obtained Any of the other exemptions in the Act apply as per the exemption list: There are 23 exemptions from rights of access under the Act. Further guidance on the exemptions can be found at: ICO - FOI Exemptions Absolute Exemptions (AE) – if an absolute exemption applies, there is no obligation under the Act to consider the request for information further Qualified Exemptions (QE) – are subject to the public interest test. Qualified exemptions do not justify withholding information unless, following a proper assessment, the balance of the public interest is against disclosure. When applying a qualified exemption, the deadline may be extended to consider fully where the balance of public interest lies.
List of exemptions AE Section 21 Information accessible to applicant by other means AE Section 23 Information supplied by, or relating to, bodies with security matters AE Section 32 Court records AE Section 34 Parliamentary privilege AE Section 36 Prejudice to effective conduct of public affairs (so far as relating to information held by the House of Commons or the House of Lords). AE Section 40 Personal information (where the applicant is the data subject) AE Section 41 Information provided in confidence AE Section 44 Prohibitions on disclosure QE Section 22 Information intended for future publication QE Section 24 National security QE Section 26 Defence QE Section 27 International relations QE Section 28 Relations within the United Kingdom QE Section 29 The economy QE Section 30 Investigations and proceedings conducted by public authorities QE Section 31 Law enforcement QE Section 33 Audit functions QE Section 35 Formulation of Government policy QE Section 36 Prejudice to effective conduct of public affairs (for all public authorities except the House of Commons and the House of Lords) QE Section 37 Communications with His Majesty, etc and honours QE Section 38 Health and safety QE Section 39 Environmental information QE Section 40 Personal information (where the applicant is not the data subject) QE Section 42 Legal professional privilege QE Section 43 Commercial interests A full copy of the Act including further information on the exemptions can be found at: http://www.legislation.gov.uk/ukpga/2000/36/contents
If it is a qualified exemption, have you considered the public interest test (PIT)? For example, would the release of the information cause any harm (prejudice) and even if it would, does the public interest still favour disclosure? The burden is on the organisation to show that the public interest in withholding the information is greater than the public interest in disclosure. Where possible, use specific arguments, i.e., what harm/prejudice would occur by releasing this information. If the balance falls 50:50, then information should be released.
If the response is late, please give the reasons for this:
If a public interest test extension has been applied, please give the reasons:
Reminder to include the standard complaints paragraphs at the end of your response: If you are unhappy with the result of your request for information, you may request an internal review within two calendar months of the date of this letter by writing to: Greengate Medical entre, 497 Barking Road, E13 8PS If you remain unhappy with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: Information Commissioner Wycliffe House Water Lane WILMSLOW SK9 5AF
Any other comments:

FOI acknowledgement letter

Dear Sir/Madam,

FREEDOM OF INFORMATION ACT 2000

Thank you for your request for information under the requirements of the Freedom of Information Act 2000.  We started work on this request on [insert date]. As per Section 10 of the Act, you can expect a reply no later than 28 Working Days from this date. Therefore the expected reply date for your request is [insert date].

There may be a fee payable for this information. This will be considered and you will be informed if a fee is payable. In this event, the fee must be paid before the information is processed and released. The 20-day time limit for responses is suspended until receipt of the payment. If there is a fee payable, we will write to you again to let you know the process in this event.

For your information, the Act defines a number of exemptions that may prevent the release of the information you have requested. We will assess whether any of the exemption categories apply to your request (as per Part 11 of the Act) and if they do, or if there is a delay due to the application of an exemption, we will write to you again.  

If any further assistance in this matter is required, please do not hesitate to contact me again.

Further information is also available from the Information Commissioner at:

Information Commissioner's Office
Wycliffe House
Water Lane
WILMSLOW
SK9 5AF

Telephone: 0303 123 1113

www.ico.org.uk

Yours sincerely,

[Insert name and role]

FOI response letter

Dear Sir/Madam,

FREEDOM OF INFORMATION ACT 2000

Thank you for your request for information under the requirements of the Freedom of Information Act 2000.  You asked for information regarding [copy in request details here]

Following consideration of your request for information, I will answer your queries below in turn:

[Response here]

If you are unhappy with the result of your request for information, you may request an internal review within two calendar months of the date of this letter by writing to:

[insert name, address and email]

If you remain unhappy with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision.

Further information is also available from the Information Commissioner at:

Information Commissioner's Office
Wycliffe House
Water Lane
WILMSLOW
SK9 5AF

Telephone: 0303 123 1113

www.ico.org.uk

Yours sincerely,

[Insert name and role]

PIT requirement delay letter

Dear Sir/Madam

FREEDOM OF INFORMATION ACT 2000

Thank you for your letter/email received on [insert date]. Your request for information is being considered.

It is not possible to confirm or deny that the information you requested is held and/or to provide the information as this may not be in the public interest. The organisation is currently assessing this.

The exemption that may apply is Section [insert and provide an explanation]. It is anticipated that this will require additional time to process this request. The anticipated date for a decision is [insert date]. If this timescale needs to be revised, I will write to you again as to the reasons and provide you with a revised timescale.

If any further assistance in this matter is required, please do not hesitate to contact me again.

Further information is also available from the Information Commissioner at:

Information Commissioner's Office
Wycliffe House
Water Lane
WILMSLOW
SK9 5AF

Telephone: 0303 123 1113

www.ico.org.uk

Yours sincerely,

[Insert name and role]

Record of public interest test meeting under the Freedom of Information Act 2000

Information available from this organisation that provides medical services under contract to the NHS under the Freedom of Information Act model publication scheme.

Class 1 – Who we are and what we do
Information to be published	How the information can be obtained	Cost
Organisational information, structures, locations and contacts	For example, organisation website, organisation information leaflet	Free
Doctors in the organisation
Contact details for the organisation (named contacts with telephone numbers and email addresses)
Opening hours
Other staffing details
Meeting information – specifically with pharmaceutical companies and other medical suppliers
Class 2 – What we spend and how we spend it
Information to be published	How the information can be obtained	Cost
Financial information relating to projected and actual income, expenditure, procurement, contracts and financial audit. This should be the current and previous financial year’s information
Details on NHS funding received by the organisation. It is expected that practices will consider publishing as much information as is practically possible, including as much detail as possible
Audit of NHS income
Details of expenditure items over £10,000 – published at least annually but at a quarterly or six monthly interval where practical
List and value of contracts awarded by the organisation. It would normally only be expected that the organisation publishes details of contracts that are of sufficient size to have gone through a formal tendering process.
Staff allowances and expenses that can be incurred or claimed, with totals paid to senior staff members (for the purpose of this document, ‘senior staff’ are defined as partners or equivalent level) with references to categories
Pay policy
Declaration of GPs’ NHS/HSC income. The information made available as part of GPs’ contractual obligation to publish their net income relating to NHS/HSC contracts, once this obligation is in force. A link may be provided to the information on a third-party website and/or a description of where this information is available
Class 3 – What our priorities are and how we are doing
Information to be published	How the information can be obtained	Cost
Strategies and plans, performance indicators, audits, inspections and reviews. Current and previous year as a minimum
Plans for the development and provision of NHS services
Performance data, including performance against targets
Inspection reports by regulators: the CQC, HIW, RQIA and HSCB and any other regulators
Class 4 – How we make decisions
Information to be published	How the information can be obtained	Cost
Decision-making processes and records of decisions Current and previous year as a minimum
Records of decisions made in the organisation affecting the provision of NHS services
Class 4 – Our policies and procedures
Information to be published	How the information can be obtained	Cost
Current written protocols, policies and procedures for delivering our services and responsibilities. Mark ‘not held’ against any policies that are not available
Policies and procedures about customer service
Internal instructions to staff and policies relating to the delivery of services
Policies and procedures about the recruitment and employment of staff
Equality and diversity policy
Health and safety policy
Complaints procedures (including those covering requests for information and operating the publication scheme)
Records management policies (records retention, destruction and archive)
Data protection policies
Policies and procedures for handling requests for information
Class 6 – Lists and registers
Information to be published	How the information can be obtained	Cost
It is recognised that it is unlikely that GPs are going to have registers available for public inspection and, while this remains the case, ‘none held’ can be entered in this section
Any publicly available register or list (if any are held, this should be publicised. In most circumstances existing access provisions will suffice)
Class 7 – The services we offer
Information to be published	How the information can be obtained	Cost
Information about the services offered including leaflets, guidance and newsletters produced for the public
The services provided under contract to the NHS
Charges for any of these services
Information leaflets
Out-of-hours arrangements